EFTA00221751.pdf

Case 9:08-cv-80119-KAM Document 90-2 Entered on FLSD Docket 05/05/2009 Pag Vit JANE DOE NO. 2, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINITFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 2, by and through her undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby resRonds toptefendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as fo4oWs: General Objections 1. Plaintiff objects to Defendants Interrogatories to the extent that the Interrogatories call for the disclosure of information protected by the attorney-client privilege, attorney work-product doctrine, or other applicable privilege or immunity, whether created by statute or common law. Plaintiff claims such privileges and protections to the extent implicated by each Interrogatory, and excludes privileged and protected information from any responses to Defendant's discovery. Any disclosure is inadvertent and is not intended to waive those privileges or protections, which are specifically reserved. 2. Plaintiff objects to Defendant's Interrogatories to the extent that same are vague, ambiguous, incomprehensible and/or overly broad. " A I V EFTA00221751 Case 9:08-cv-80119-KAM Document 90-2 Entered on FLSD Docket 05/05/2009 Page 2 of 4 Doe No. 2 v. Epstein Page 8 9. Describe each injury (physical, emotional, mental) for which you are claiming damages in this case, specifying the part of your body that was injured, the nature of the injury, and as to any injuries you contend are permanent, the effects on you that you claim are permanent. Answer: Plaintiff has suffered severe psychological and emotional injuries, including without limitation, anxiety, low self-esteem, feelings of guilt, self-blame, distrustfulness, burdened often by sadness and depression, suicidal thoughts, difficulty trusting others (particularly men), irritability, anger, feeling helpless and powerless, escapism through excessive partying, lack of confidence, loss of innocence. Plaintiffs psychological and emotional injuries will be analyzed by a forensic expert, whose opinions and related information will be disclosed in accordance with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff reserves the right to supplement this response in accordance with the Federal Rules of Civil Procedure. 10. Please state each item of damage that you claim, and include in your answer: the count to which the item of damages relates; the factual basis for each item of damages; and an explanation of how you computed each item of damages, including any mathematical formula used. Answer: Plaintiff objects to this interrogatory as calling for an expert opinion and calculation. Subject to said objection, Plaintiff states that she seeks damages arising from her psychological and emotional injuries. These damages include pain and suffering, costs of psychological care and treatment, and loss of earning capacity. The pecuniary elements of these damages will be analyzed and computed by an appropriate expert. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, etc.) or medical provider (including chiropractors) who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this EFTA00221752 Case 9:08-cv-80119-KAM Document 90-2 Entered on FLSD Docket 05/05/2009 Page 3 of 4 VERIFICATION being duly sworn, deposes and says that the foregoing an ewers to interrogatories are true and correct to the best of her knowledge, information and belief. STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ) before me this ,LL day of 2009 by who is personally known to me or has produced the following identification ". 4 id P. which is current or has been issued within the past five years and bears a serial or other identifying number. E.-Jetty a CO-€5 e iti Print Name rx 27, ,b. Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) .5-4734 e. tr-PIL IR7;10 EFTA00221753 Mail and facsimile to the following addressees this Robert D. Critton, Jr, Esq. Burman, Critton, Luther & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax V VT IP '• WV V • Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 Co-Counsel for Defendant Jeffrey Epstein Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 305-442-1101 Fax: 305 442 6744 Co-Counsel for Defendant Jeffrey Epstein tein@liewisteinfnm Case 9:08-cv-80119-KAM Document 90-2 Entered on FLSD Docket 05/05/2009 Page 4 of 4 Doe No. 2 v. Epstein Page 16 Certificate of Service WE HEREBY CERTIFY that a true copy of t oregoing has been sent via U.S. day of January, 2009. EFTA00221754